Required minimum distributions on your own IRA or 401(k) in the UK

This guide is for people living in the UK who own a US retirement account they built themselves: a traditional IRA, a SEP or SIMPLE IRA, a 401(k) or a 403(b). From your applicable age — 73 or 75, depending on when you were born — US law forces a minimum amount out each year, whether you need it or not. The UK taxes that payment in full as foreign pension income, and a US citizen is taxed in the US too, with the US crediting the UK tax, not the reverse. Inherited accounts follow their own rules for UK beneficiaries.

When do RMDs start — at 73 or at 75?

Your date of birth decides it, not the year you retire and not where you live. The applicable age, as rewritten by the SECURE 2.0 Act of 2022, is 73 for anyone born between 1 January 1951 and 31 December 1958, and 75 for anyone born on or after 1 January 1960^[1][2]; the final regulations, TD 10001, apply to distribution years beginning on or after 1 January 2025^[3]. Nothing in UK law requires the distribution: the obligation is American and attaches to the account, not the owner’s residence.

Applicable age for required minimum distributions, by date of birth (earlier cohorts used 70½ or 72)

Date of birth	Applicable age	Authority
1 January 1951 to 31 December 1958	73	1.401(a)(9)-2(b)(2); TD 10001[2][3]
During 1959	73 under a proposed rule, not yet final	REG-103529-23[4]
On or after 1 January 1960	75	1.401(a)(9)-2(b)(2); TD 10001[2][3]

What is my required beginning date, and why can 1 April cost me?

It is 1 April of the year after the year you reach your applicable age. For an employer plan it can be later — 1 April following the year you retire, if you are not a 5% owner of the sponsoring business^[1][2]. An IRA has no retirement limb, so age alone fixes the date^[5]. Every RMD after the first is due by 31 December of its own year^[6].

The first year carries a choice, and deferral is rarely free. Someone taking the first distribution by the following 1 April “must receive their second RMD” by 31 December of that same year, and “even though the first distribution is actually the required” prior-year distribution, “it’s taxable” in the later year^[9]. Two RMDs fall into one US tax year.

That hurts more for a cross-border household, because the tax years do not line up: the UK taxes each payment in the year it arises^[16][17], so the US bunches two distributions into 2027 while the UK keeps them a year apart. Taking the first RMD by 31 December of the first year keeps one in each year on both sides.

How is the required amount worked out?

Take the balance at 31 December of the preceding year and divide it by a divisor read from your age^[5][8]. A first RMD due by 1 April 2027 uses the balance at 31 December 2025, because 2026 is the distribution year^[5]. The divisors are in the Uniform Lifetime Table in the Treasury regulations^[7], reproduced as Table III in Publication 590-B^[8].

Uniform Lifetime Table: distribution periods (divisors) for ages 73 to 95, from 26 CFR 1.401(a)(9)-9(c)^[7]

Age	Divisor	Age	Divisor	Age	Divisor
73	26.5	81	19.4	89	12.9
74	25.5	82	18.5	90	12.2
75	24.6	83	17.7	91	11.5
76	23.7	84	16.8	92	10.8
77	22.9	85	16.0	93	10.1
78	22.0	86	15.2	94	9.5
79	21.1	87	14.4	95	8.9
80	20.2	88	13.7

As percentages — illustrative arithmetic from the divisors — that is about 3.8% of the balance at 73, 5.0% at 80, 6.25% at 85 and about 11.2% at 95: the share rises every year by design. The divisor is fixed by age; the balance is not, so the payment and the sterling tax on it move with markets and the exchange rate.

One exception: where your spouse is the sole beneficiary and more than ten years younger, the longer Joint and Last Survivor Table applies instead, using both ages^[7][8]. Publication 590-B’s example gives an owner reaching 75 with a spouse reaching 64 a divisor of 25.3, against 24.6 on the Uniform Lifetime Table^[8].

Which accounts can I add together?

IRAs aggregate with IRAs; employer plans do not aggregate at all. An IRA owner “must calculate the RMD separately for each IRA” but “can withdraw the total amount from one or more of the IRAs”, while RMDs from 401(k) and 457(b) plans “must be taken separately from each of those plan accounts”^[5]. That freedom is useful from Britain: the whole IRA requirement can come from whichever account is simplest to liquidate, or whose currency position suits a sterling spender.

Which US retirement accounts can be aggregated for RMD purposes

Account type	Computed separately?	Can the total be taken from one account?
Traditional, SEP and SIMPLE IRAs	Yes, per IRA	Yes — from any one or more of your IRAs[5]
403(b) contracts	Yes, per contract	Yes, but only among your 403(b) contracts[5]
401(k) and 457(b) plans	Yes, per plan	No — each plan pays its own[5]
Roth IRA	No lifetime RMD	Not applicable[6][8]

One rule covers every account: an RMD can never be rolled over, moved to another retirement account or converted to a Roth, because the Code excludes required amounts from the IRA rollover provisions and from the definition of an eligible rollover distribution^[10][11]. In any year an RMD is due it comes out first; only what is left above it can be converted.

Can I delay a 401(k) RMD if I am still working, and do Roth accounts have RMDs?

The still-working exception covers employer plans only, never IRAs. Workplace plan participants “can delay taking their RMDs until the year in which they retire, unless they’re a 5% owner of the business sponsoring the plan”^[5]. Three limits: it covers only the plan of the employer you still work for^[5]; the plan document must permit it, and some plans require distributions at the applicable age regardless^[6]; and a 5% owner — broadly, someone owning more than 5% of the employer — gets no deferral^[2][5].

No minimum distributions are required from a Roth IRA during the owner’s life^[6][8], and designated Roth accounts inside 401(k) and 403(b) plans lost their lifetime RMD for taxable years beginning after 31 December 2023^[3][6].

That matters more here than in America. HMRC’s manual applies Article 17(1)(b) of the treaty to IRAs: a distribution is “exempt from tax in the UK to the same extent that the distribution would be exempt from tax in the US”^[18]. A qualified Roth distribution is tax-free in the US, so on that view it should be free of UK tax too — and nothing forces it out, making a Roth the one US account a UK resident can leave alone.

How does the UK tax an RMD?

In full, as foreign pension income, in the UK tax year in which it arises, at your marginal rate. UK law charges “the full amount of the pension income arising in the tax year”^[17], and HMRC confirms the change that caught many people out: “from 6 April 2017 the taxable amount is full amount of the payment arising in the tax year”, against 90% before that date^[16]. Liability arises only if the recipient is UK resident^[16].

For 2026/27 the personal allowance is £12,570, the 20% basic rate runs to £50,270, the 40% higher rate to £125,140, and 45% applies above that; the allowance falls by £1 for every £2 of income over £100,000 and is gone at £125,140^[23]. That taper makes an effective rate of about 60% between £100,000 and £125,140, the most expensive band an RMD can land in. Scottish rates differ. The payment is reported on the SA106 foreign pages^[21].

Two refinements. Any part of a distribution that would not be taxable in the US — a return of after-tax basis, or a qualified Roth payment — is exempt in the UK to the same extent on HMRC’s stated view^[18]. And a person in their first four UK tax years after at least ten years abroad may claim the four-year foreign income and gains regime, which replaced the remittance basis from 6 April 2025 and covers foreign pension income^[26] — a claim with costs of its own, and one for an adviser.

If the treaty taxes pensions where I live, why does the US still tax me?

Because the provision that would stop the US is not protected from the saving clause. Article 17(1)(a) of the 2001 treaty says pensions beneficially owned by a resident of one country “shall be taxable only in that State” — for a UK resident, only in the UK^[19]. Read alone, that would put an RMD beyond the IRS. But Article 1(4) lets a country tax its own citizens “as if this Convention had not come into effect”, and Article 1(5) lists what survives that saving clause: for Article 17, only sub-paragraph (b) of paragraph 1, and paragraphs 3 and 5^[19]. Article 17(1)(a) is not on the list.

So a UK resident who is a US citizen or long-term resident stays taxable in the US on the RMD, despite the words “taxable only in that State”; a UK resident who is not a US person does get Article 17(1)(a), because the saving clause reaches only a country’s own citizens.

Relief runs through Article 24(6). Sub-paragraph (b) provides that the UK takes into account only the tax, if any, that the US may impose under the Convention on a UK resident who is not a US citizen; (c) that the US “shall allow as a credit against United States tax the income tax and capital gains tax paid to the United Kingdom”; and (d) that the income is deemed to arise in the UK to the extent necessary to avoid double taxation^[19].

Together those set an order of payment. The tax the treaty permits the US to charge a non-citizen UK resident on this pension is nil, so under 24(6)(b) the UK gives no credit for US tax; under (c) and (d) the UK tax is credited against the US tax and the income re-sourced to the UK so the credit can be used. The UK is paid first and in full; the US relieves.

Who may tax an RMD from a US retirement account paid to a UK resident

	UK resident, not a US person	UK resident who is a US citizen or green-card holder
UK income tax	Yes, full sterling amount at marginal rates[16][17]	The same[16][17]
US income tax	No — Article 17(1)(a) gives the UK the exclusive right[19]	Yes — the saving clause applies, as 17(1)(a) is unprotected[19]
Recovering over-withheld US tax	From the IRS on a US return — HMRC does not refund it[20]	As an overpayment on the US return[15]

Will the US withhold tax on my RMD?

Yes, and you cannot switch it off from a UK address. For a US citizen or green-card holder a nonperiodic distribution carries 10% withholding by default, and the election to take less is blocked where the money goes abroad: Form W-4R says “generally, you can’t choose less than 10% for payments to be delivered outside the United States and its territories”^[13][14]. A UK resident who is not a US person starts at 30% of the gross payment, which the paying agent cannot reduce without a valid Form W-8BEN treaty claim^[15].

Withholding is a payment on account, not a final tax, but it is a cash-flow cost: the dollars sit with the IRS until a US return reclaims them, and US tax the treaty did not permit is not creditable in the UK^[20].

Why do the two tax years cause credit problems?

Because each country’s credit is capped by reference to its own year, and the years do not coincide. The US taxes individuals on the calendar year; UK 2026/27 runs from 6 April 2026 to 5 April 2027^[23]. An RMD taken in December 2026 and one in February 2027 therefore sit in the same UK year but different US years.

HMRC caps the UK credit at the lower of the foreign tax allowed by the agreement and the UK tax on that income; any excess “is not available for credit against the UK tax liability”, and HMRC points the taxpayer to the foreign tax authority to recover it^[20]. The US caps its credit by the ratio of foreign-source to total taxable income, with excess credits carried back one year and forward up to ten^[22].

Timing compounds it: a US return is due the following 15 April, extended to 15 June for a citizen abroad^[27], while the UK tax on the overlapping year is not quantified until a return filed months later. The RMD is compulsory; its date within the year usually is not.

What happens if I miss an RMD?

An excise tax of 25% of the shortfall, reduced to 10% if you put it right in time. The Code taxes the amount by which the required distribution exceeds what was distributed, and substitutes 10% where the shortfall is paid and a return filed within the correction window — broadly, the last day of the second taxable year beginning after the year the tax arose^[12]. The IRS can waive it for “reasonable error” where remedial steps are being taken; it is reported on Form 5329^[12][6].

People abroad are more exposed: a custodian may not pay automatically, post may arrive late, and a small plan from an early job is easy to lose track of. None of that shifts the obligation, and credit relief is given for foreign tax on the income, not for a penalty, so the excise tax is a cost in its own right^[20].

Can I give an RMD to charity, and how do dollars meet a sterling tax bill?

A qualified charitable distribution (QCD) works against US tax, and only for a US charity. From age 70½ you can send money straight from an IRA to an eligible charity, exclude it from US gross income and count it towards your RMD^[10][8]. For 2026 the limit is $111,000 per taxpayer, with a one-time election of up to $55,000 for a split-interest entity^[24]. QCDs come from IRAs, not 401(k) plans^[10]. The recipient must be created or organised under US law; foreign organisations, bar narrow exceptions for certain Canadian, Israeli and Mexican bodies, do not qualify^[25] — so a British charity cannot receive one.

The currency point recurs every year. The required amount is set in dollars; the UK tax is assessed in sterling, converted at the rate when the income arose^[21]. Two effects move together: a weaker pound inflates both the sterling value of the money and the sterling tax on it, a stronger pound shrinks both. A distribution comfortably inside the basic rate band at one exchange rate can cross into the higher rate at another, with nothing else changed. We found no HMRC statement expressly permitting an annual average rate for foreign pension income on the SA106 pages, so do not assume one. See our guides to currency risk in retirement and cross-border tax reporting.

Worked example: a first RMD year for a UK-resident American

Fictional household, illustrative only, not a forecast or a recommendation. Margaret Hollis was born on 14 March 1953, so her applicable age is 73 and 2026 is her first distribution year^[2]. She is a US citizen, widowed, files single in the US, has been UK resident for twelve years and has no other income; her daughter is her beneficiary, so the Uniform Lifetime Table applies. Assumptions: $1.30 to the pound held flat; UK 2026/27 rates^[23]; US 2026 single rates and the basic standard deduction only^[28] — the additional standard deduction of $2,050 available at 65 and over, and any other deduction she might claim, are left out, and both would reduce the US figure further^[29]. The figures are our own rounded arithmetic from the published table and rates, not output from Edale’s planner.

Margaret’s 2026 required minimum distributions (IRAs may be drawn in aggregate, the 401(k) only from itself), illustrative

Account	Balance at 31 Dec 2025	Divisor at 73	Required amount
Traditional IRA A	$620,000	26.5	about $23,396
Traditional IRA B (401(k) rollover)	$180,000	26.5	about $6,792
IRA subtotal	$800,000	26.5	about $30,189
Former employer’s 401(k)	$400,000	26.5	about $15,094
Roth IRA	$150,000	none	nil
Total for 2026	$1,200,000 subject to RMD		about $45,283

At the assumed rate that is about £34,833 of foreign pension income. The £12,570 personal allowance leaves about £22,263 taxed at 20%, so UK tax of roughly £4,453^[23]. On the US side, $45,283 less the 2026 single standard deduction of $16,100 leaves $29,183 taxable, about $3,254 of tax^[28]. Her UK tax, about $5,789 at the assumed rate, is the larger: under Article 24(6)(c) and (d) the income is treated as arising in the UK and the UK tax credited against the US tax, which should extinguish it and leave excess credit to carry forward^[19][22]. Her custodians will still withhold at least 10%, about $4,528, recoverable from the IRS rather than HMRC^[13][14].

Taking the first RMD by 31 December 2026 against deferring it to 1 April 2027, illustrative

	Paid by 31 December 2026	Deferred to March 2027
US calendar 2026	one RMD, about $45,283	nil
US calendar 2027	one RMD	two RMDs, roughly $90,000 before market movement[9]
UK 2026/27 and 2027/28	one RMD in each	one RMD in each, paid in March and December 2027

Deferring raises the US marginal rate on part of the income and splits the matching UK tax across two UK years, so the credit claimed on the US 2027 return is measured against UK tax sitting only partly in the corresponding UK year. Nothing is lost permanently, but cash is tied up and a reconciliation follows. Whether the same holds for you depends on your own income and accounts: this is general information, not personal advice.

How the Edale Wealth Hub helps

An adviser using Edale’s planner with a client forecasts required minimum distributions for the relevant accounts year by year: it takes the prior 31 December balance — from the holdings in the plan, or entered by hand — applies that year’s divisor, and shows the required amount in dollars and sterling against what has already been paid out.

The cashflow planner then puts those distributions in context across both countries, so a client can see what drawing only the minimum does to tax in the UK and the US over the whole of retirement, and what drawing more than the minimum does instead. The first-year choice — taking the first distribution by 31 December or deferring it to the following 1 April — can be compared as two scenarios.

Results rest on assumptions about growth, inflation, exchange rates and tax rules, and are not guaranteed. The tax outputs are summaries for your accountant or tax preparer; Edale does not prepare US tax returns. Arrange a conversation or read about the planner.

Frequently asked questions

Do I have to take RMDs from my US accounts if I live in the UK?

Yes. The obligation attaches to the account, not to where you live, so a UK resident with a traditional IRA, 401(k) or 403(b) must take the required amount each year from their applicable age. Roth accounts carry no lifetime requirement.

Is my RMD age 73 or 75?

It depends on your date of birth: 73 if you were born between 1 January 1951 and 31 December 1958, and 75 if you were born on or after 1 January 1960. Your required beginning date is 1 April of the year after you reach it.

I was born in 1959 — which age applies to me?

This is unsettled. The statute points to both 73 and 75 for that single birth year, and the final regulations skip it. The IRS has proposed 73 for 1959 births but has not finalised it, so check your own position with a US tax preparer.

Does the UK tax my required minimum distribution?

Yes, if you are UK resident. The whole payment is taxed as foreign pension income in the UK tax year in which it arises, at your marginal rate; the old 10% deduction went in April 2017. Any part that is tax-free in the US should be exempt here too.

The treaty says pensions are taxed where I live, so why am I taxed in the US?

Because Article 17(1)(a) is not protected from the treaty’s saving clause, which lets the US tax its own citizens as if the treaty did not exist. Only Article 17(1)(b) and paragraphs 3 and 5 survive it. The US then credits your UK tax under Article 24(6).

Can I convert my RMD to a Roth IRA or put it in an ISA?

An RMD can never be rolled over or converted to a Roth: the required amount must come out first, and only money above it can be converted. Cash can be invested afterwards, but for a US person an ISA is not tax-free in the US.

Can I give my RMD to charity and avoid tax in both countries?

Only partly, and the UK side is unresolved. A qualified charitable distribution from an IRA at 70½ or older is excluded from US gross income, up to $111,000 in 2026, and counts towards your RMD — but it must go to a US organisation, and no HMRC guidance puts it outside the UK charge.

Sources

1. Legal Information Institute, Cornell Law School — 26 U.S. Code § 401 (required minimum distributions; applicable age; required beginning date) (accessed October 2026)
2. eCFR — 26 CFR 1.401(a)(9)-2, Distributions commencing during an employee’s lifetime (accessed October 2026)
3. Federal Register — Required Minimum Distributions, final regulations (TD 10001), 19 July 2024 (accessed October 2026)
4. Federal Register — Required Minimum Distributions, proposed regulations (REG-103529-23), 19 July 2024 (accessed October 2026)
5. IRS — Retirement plan and IRA required minimum distributions FAQs (accessed October 2026)
6. IRS — Retirement topics: Required minimum distributions (RMDs) (accessed October 2026)
7. eCFR — 26 CFR 1.401(a)(9)-9, Life expectancy and distribution period tables (Uniform Lifetime Table at paragraph (c)) (accessed October 2026)
8. IRS — Publication 590-B, Distributions from Individual Retirement Arrangements (IRAs) (accessed October 2026)
9. IRS — IR-2023-43, Reminder to many retirees: last day to start taking money out of IRAs and 401(k)s is April 1 (accessed October 2026)
10. Legal Information Institute, Cornell Law School — 26 U.S. Code § 408 (IRAs; no rollover of a required distribution; qualified charitable distributions) (accessed October 2026)
11. Legal Information Institute, Cornell Law School — 26 U.S. Code § 402(c)(4)(B) (a required distribution is not an eligible rollover distribution) (accessed October 2026)
12. Legal Information Institute, Cornell Law School — 26 U.S. Code § 4974 (excise tax on accumulations; reduction to 10%; correction window; waiver) (accessed October 2026)
13. Legal Information Institute, Cornell Law School — 26 U.S. Code § 3405 (withholding on pensions and annuities; no election out where delivered outside the United States) (accessed October 2026)
14. IRS — Form W-4R, Withholding Certificate for Nonperiodic Payments and Eligible Rollover Distributions (accessed October 2026)
15. IRS — Plan distributions to foreign persons require withholding (accessed October 2026)
16. HMRC — Employment Income Manual EIM75500, The taxation of pension income: foreign pensions (accessed October 2026)
17. legislation.gov.uk — Income Tax (Earnings and Pensions) Act 2003, section 575 (taxable pension income) (accessed October 2026)
18. HMRC — Double Taxation Relief Manual DT19853, United States of America: notes (accessed October 2026)
19. US Treasury — Convention between the United States and the United Kingdom for the avoidance of double taxation, signed 24 July 2001 (Articles 1(4), 1(5), 17 and 24) (accessed October 2026)
20. HMRC — Relief for foreign tax paid 2026 (HS263), Self Assessment helpsheet (accessed October 2026)
21. HMRC — Foreign notes (SA106 Notes 2026), tax year 6 April 2025 to 5 April 2026 (accessed October 2026)
22. Legal Information Institute, Cornell Law School — 26 U.S. Code § 904 (limitation on the foreign tax credit; one-year carryback and ten-year carryforward) (accessed October 2026)
23. GOV.UK — Income Tax rates and Personal Allowances (2026 to 2027) (accessed October 2026)
24. IRS — Notice 2025-67, 2026 limitations (qualified charitable distribution limit $111,000; split-interest election $55,000) (accessed October 2026)
25. IRS — Publication 526, Charitable Contributions (qualified organisations; foreign organisations) (accessed October 2026)
26. HMRC — HS266 Foreign income and gains (FIG) regime (2026) (accessed October 2026)
27. IRS — U.S. citizens and resident aliens abroad (filing dates and extensions) (accessed October 2026)
28. IRS — Tax inflation adjustments for tax year 2026, including amendments from the One, Big, Beautiful Bill (IR-2025-103) (accessed October 2026)
29. IRS — Revenue Procedure 2025-32, inflation-adjusted items for 2026 (standard deduction; additional standard deduction for the aged) (accessed October 2026)

Related guides

• US–UK wealth planning: the complete guide
• 401(k)s, IRAs and Roth IRAs when you live in the UK
• Inheriting a US IRA while living in the UK: rules, tax and timing
• GBP/USD currency risk in retirement for US–UK families
• How much can I spend in retirement? A cross-border guide